Switzerland’s Federal Council has launched a public consultation on amendments to the Minimum Taxation Ordinance (MTO), introducing new reporting requirements for multinational companies under the OECD’s Pillar 2 rules.  The announcement was made on 30 April 2025.

The amendments introduce requirements for multinational groups to file Pillar 2 GloBE Information Returns (GIRs) with the Federal Tax Administration (FTA).

Under the proposed rules, one Swiss-based entity per group must submit the GIR electronically. The first deadline is 30 June 2026, covering fiscal years starting on or after 1 January 2024. If another country’s tax authority collects the GIR and shares it with Switzerland under an international agreement, the Swiss entity need only notify the FTA of the responsible entity and its location.

The changes align with the global tax framework and facilitate information exchange between jurisdictions. The consultation allows stakeholders to provide feedback before final implementation.

The OECD’s minimum taxation (Pillar 2) applies to international corporate groups with an annual turnover of at least EUR 750 million and introduces a minimum tax rate of 15% based on a standardized international tax base. This rate should, in principle, be achieved in every jurisdiction.

The regulatory framework for the Organisation for Economic Co-operation and Development’s (OECD) minimum taxation (GloBE Model Rules, Pillar 2) also includes a reporting requirement. Affected international corporate groups must submit special tax declarations known as GloBE Information Returns (GIR). These returns provide tax authorities worldwide with information on corporate groups’ income and taxes paid. Using these declarations, Swiss tax authorities can verify the plausibility of tax filings submitted by companies subject to the supplementary tax. Therefore, provisions on GIR must be added to the MTO. By implementing these rules in line with the model regulations, the Federal Council aims to ensure legal certainty and reduce the additional administrative burden for companies based in Switzerland.

Earlier, the Swiss Federal Council declared that the Pillar 2 income inclusion rule (IIR) would be effective from 1 January 2025.